Are Comment Codes 003 and 049 Treated Differently?

Award Year: 2024-25 KA-36659 Helpfulness Rating 877 page views

This guidance is specific to the 2024-25 award year and later.

Effectively, no. The text of each of the comment codes is as follows:

Effective with the 2023-24 award year, schools must reach out to all dependent students who do not provide parental data on the FAFSA (regardless of reason) to inform them about the procedures for requesting a dependency override using professional judgment (PJ), and to collect the necessary documentation.

How you proceed depends on the result of your outreach. If the student indicates provisional independent student status and requests a dependency override (003), refer to AskRegs Knowledgebase Q&A, What Are the Requirements For Implementing Provisional Independent Student Status For 2024-25?

If the student indicates they are not requesting a dependency override and just want a Direct Unsubsidized Loan (049), see AskRegs Q&A, If a Student's Parents Refuse To Provide Support, How Does the Student Complete the FAFSA To Borrow a Direct Unsubsidized Loan?

Reference Dear Colleague Letter GEN-22-15.

Self-Evaluation Checklists: You may consider using NASFAA's Self-Evaluation Checklists, formerly NASFAA's Self-Evaluation Guide, to audit and evaluate your institution's programs related to this topic. It allows administrators to evaluate processes in a centralized, shared, online space. This tool is free for all NASFAA members.

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